AP4388 - Deceased Persons: Liaison and exchange of information with HMRC Inheritance Tax

The Risk and Research Team in HMRC Inheritance Tax (IHT) Nottingham supply information direct to Area Offices on form 984. This will be for those estates where the IHT Account contains information that may be helpful in deciding whether enquiries for periods up to the date of death need to be opened.

RIAT Managers can also ask HMRC IHT for information on form 982 where no form 984 has been received. The liaison arrangements with HMRC IHT in cases reviewed or taken up for enquiry are outlined in EM3250.

Where an Area Office decides to open an enquiry into the deceased’s affairs, it is possible that the administration period liability will be dealt with in a specialist Trusts Office. It is important in such enquiry cases to maintain close liaison between the Area Office, the specialist Trusts Office and HMRC IHT.

Either HMRC Trusts Edinburgh, one of the other specialist Trust Offices, or the designated office will be responsible for finalising the administration period liability where one or more of the following criteria apply:

• the tax liability for the whole of the administration period is in excess of £10,000
• the estate has a value at the date of death in excess of £2.5m
• the proceeds of assets sold in any one tax year by the personal representatives exceed £250,000
• the administration of the estate extends beyond the end of the second full tax year from the date of death
• the estate does not fall into any of the above categories but is not straightforward so cannot easily be dealt with under the informal payments procedures (see TSEM7366 and TSEM7376)
• a trust is created under the terms of the deceased’s will or the rules of intestacy (TSEM7366 and TSEM7378)
• a corporate trustee is acting (TSEM7366)
• the GCD of the deceased was PD1 who will also deal with the period of administration
• the deceased was a Lloyds Underwriter and West Yorks Personal Tax Unit will deal with the period of administration.